Document a1Vxax91ke5oo7M7gbDgOEEaX

ec; G, H. Bruxelles - Hercules - Wilmington P. G. Linsen - Pi - H10539 Decemoer 15, 1^7% Mr. Edward J. Baler, Deputy Director Department of Health, Education and Welfare national Institute for Occupational Safety and Health 5600 Fishers Lane ' Rockville, Maryland 20852 Dear Ed;* r I thank, you for sending a copy of the report "by the HIOSH Division of Surveillance,. Hazard Evaluations, and .Field Studies of .a review of our DCMA Epidemiology Study of workers in lead chromate pigments plants. Some of the statements in the critical review .seem to reflect adversely not only on the technical aspects of the work hut also on the ability of the authors to deal fairly with the subject matter. For this reason, 1 asked that Equitable Environmental Health .study your criticism and .furnish us with a response. X also requested and have obtained independent reviews of the criticism frpa Dr. .Sidney Fell, the Du Font Biostatistician, and from Dr. Joan Davies of the Chester Beatty Research Institute, Institute of Cancer Research, Royal Cancer Hospital in London, England, The net result of the responses I have received are that the NICSH reviewer has aside several errors of fact and. several errors of interpretation or judgment. The response that was prepared by Dp. W. Clark Cooper of Equit able Environmental Health Inc. covers nearly all of the points that were made by the several reviewers and, in addition, furnishes some added facts which might be useful to your Division of Surveillance, Hazard Evaluations, and Field Studies. For this reason, I attach Dr. Cooper's comments in their entirely. Dr. Pall's comments are also attached. A marked, copy of Ms Robinson1 s critique carries the principal comments submitted by Dr. Davies. In the last paragraph on page 3 of Ms letter, Dr. Cooper has indulged in an expression of his opinion of what the future may disclose. That is Ms privilege. He urges continued follow-up of this and similar populations. TMs advice has been accepted. His recommendation -for individualized study of gastrointestinal tract cancers is being actively carried out right now. N 27677 DUP04001M81 We are all agreed) Ed, that the HICSH comment about a dearth of subjects ia>. tbs study is regrettable but true. I think; that you can. appreciate the origin, of this study and, understanding It, accent some of its in evitable shortcomings. The pigment manufacturing industry was faced with suggestions that the lead chromate pigments which they had been manu facturing and selling for years had a relationship to the occurrence of human lung cancer. The initial step in trying to determine the validity of the suggested link was obviously to study the mortality records of workers who had been exposed during past decades. The services of a most competent firm were engaged, end full, cooperation - nr. evton'vv in fUrnifibin? records on which a study could be based. In this c pu a, er in many others, the records of employment, exposure, health, erd death in past dncade.t were not; nearly as complete as would now he clecireiThe invest is;: tire firm^ .Hquibable Environmental Health, bad to rake the most of whrt ir ''Y'.'-ilrble. We think a thorough and competent job was done. The DCMA acted with a sense of responsibility ard with speed in informing filCSK of the inception, progress, and results of the study. Sincerely, James F Morgan attachments Additional Copies to; Dr. Morton Corn Assistant Secretary of Labor u s d o l /o s h a Washington, D.C. 20210 Mr, Gerald L. Weinstein Directorate of Health Standards Development Occupational Safety and Health Administration Department of .Labor Washington, D.C. 20210 -2- DUP040Q10982